Privacy Policy

01 Introduction

1q77 ("we," "us," "our," or "1q77") is committed to protecting the privacy and personal data of every individual who uses the 1q77 platform at 1q77.club ("Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and applicable PAGCOR data governance requirements.

This Policy applies to all players, registered users, and visitors of the 1q77 Platform, regardless of the device or connection method used to access it. Our Privacy Policy forms part of, and should be read together with, our Terms & Conditions.

02 Data Controller

1q77 is the data controller responsible for personal data processed through the 1q77 Platform. As the data controller, 1q77 determines the purposes and means of processing personal data collected from platform users. 1q77 is registered with the Philippine National Privacy Commission (NPC) in compliance with the DPA's registration requirements applicable to personal information controllers processing sensitive personal information.

All data protection inquiries, access requests, and correction requests should be directed to our Data Protection Officer (DPO) at the contact details provided in Section 14 of this Policy.

03 Personal Data We Collect

3.1 Registration Data

When you create a 1q77 account, we collect your legal full name, date of birth, residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati), Philippine mobile number, and email address. This data is necessary to create and administer your account and verify your eligibility to use the platform.

3.2 Identity Verification (KYC) Data

Prior to processing your first withdrawal, 1q77 is required by PAGCOR regulations to verify your identity. We collect copies of government-issued Philippine identification documents (such as PhilSys National ID, SSS ID, Passport, or Driver's License) and, where required, proof of address and source of funds documentation. This data is classified as sensitive personal information under the DPA.

3.3 Financial Transaction Data

We collect records of all deposits and withdrawals processed through your 1q77 account, including transaction amounts, timestamps, payment method identifiers (e.g., GCash number, PayMaya account, bank account details), and transaction reference numbers. We do not store full payment card numbers or banking credentials.

3.4 Gameplay and Activity Data

We record your gameplay activity on 1q77 — including game sessions, wager amounts, outcomes, session durations, and game preferences. This data is used for responsible gaming monitoring, fraud detection, PAGCOR compliance reporting, and platform improvement.

3.5 Technical and Device Data

We automatically collect technical data when you access 1q77, including IP address, device type and operating system, browser type and version, screen resolution, connection type, and session timestamps. This data is used for security monitoring, fraud prevention, and platform optimization.

3.6 Communications Data

If you contact 1q77 customer support via live chat or email, we retain records of those communications for quality assurance, dispute resolution, and compliance purposes.

04 How We Use Your Personal Data

1q77 uses personal data collected from you for the following purposes:

• To create, manage, and administer your 1q77 account;
• To verify your identity and eligibility in compliance with PAGCOR KYC requirements;
• To process deposits, withdrawals, and other financial transactions via GCash, PayMaya, BPI, BDO, Metrobank, and bank transfer;
• To provide access to the 1q77 game library, sports betting, and other platform services;
• To detect, investigate, and prevent fraud, money laundering, collusion, and other prohibited activities;
• To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations, and other applicable Philippine laws;
• To provide responsible gaming tools and monitor gameplay for signs of problem gambling as required by our PAGCOR license conditions;
• To respond to customer support inquiries and resolve disputes;
• To send transactional communications (account confirmations, withdrawal notifications, security alerts) via SMS or email;
• To send promotional and marketing communications where you have provided explicit consent to receive such communications.

05 Legal Basis for Processing

1q77 processes personal data on the following legal bases as defined under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to fulfill our obligations to you under the 1q77 Terms & Conditions, including account management and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AML laws, and other applicable Philippine legal requirements;
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring that is proportionate and does not override your privacy rights;
• Consent: Processing for direct marketing communications, where you have provided explicit, freely given, specific, and informed consent.

06 Disclosure of Personal Data to Third Parties

1q77 does not sell, rent, or trade your personal data. We disclose personal data only in the following circumstances:

6.1 Service Providers

We share data with carefully vetted third-party service providers who process data on our behalf under strict data processing agreements, including payment processors (GCash/GXI Corp., PayMaya/Voyager Innovations), identity verification and KYC service providers, game software providers, customer support platform operators, and cybersecurity and fraud prevention services.

6.2 Regulatory and Legal Disclosure

1q77 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts of competent jurisdiction where required to do so by applicable Philippine law, a valid court order, or a lawful regulatory direction. 1q77 will notify affected players of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or transfer of 1q77's assets or operations, personal data held by 1q77 may be transferred to the successor entity, subject to equivalent privacy protections and prior notification to affected users as required by the DPA.

07 Cookies & Tracking Technologies

1q77 uses cookies and similar tracking technologies to operate and improve the platform. The categories of cookies used include:

• Essential Cookies: Required for the platform to function — session management, authentication state, and security tokens. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences (language, game favorites) to personalize your 1q77 experience across sessions.
• Analytics Cookies: Collect aggregated, anonymized data on how players navigate and use the platform to guide product improvements. No individual player is identifiable from analytics data.
• Security Cookies: Support fraud detection and anomalous behavior monitoring by associating device fingerprints with authenticated sessions.

You may manage cookie preferences through your browser settings. Disabling essential cookies will prevent you from accessing 1q77 services.

08 Data Security

1q77 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 1q77 platform;
• AES-256 encryption for sensitive data stored on 1q77 servers;
• Multi-factor authentication options for 1q77 accounts;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular penetration testing and vulnerability assessments by qualified security professionals;
• Incident response procedures for timely detection and remediation of data security events.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 1q77 will notify affected individuals and the NPC within the timeframes required under the DPA and its implementing rules.

09 Data Retention

1q77 retains personal data for as long as your account is active and for a mandatory period following account closure. Retention periods are determined by the following considerations:

• Active account data is retained for the duration of the account relationship;
• Financial transaction records and KYC documentation are retained for a minimum of five (5) years following account closure in compliance with PAGCOR AML requirements and Philippine anti-money laundering law;
• Gameplay records relevant to responsible gaming compliance are retained for a minimum of three (3) years following account closure;
• Customer support communications are retained for two (2) years from the date of the interaction.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 1q77's data disposal procedures.

10 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 1q77:

• Right to Be Informed: The right to be informed that your personal data is being or will be collected and processed, including the purposes and legal basis for that processing;
• Right to Access: The right to request a copy of the personal data 1q77 holds about you, the manner in which it has been processed, and the recipients to whom it has been disclosed;
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data without unreasonable delay;
• Right to Erasure or Blocking: The right to request the deletion or blocking of your personal data where there is no longer a lawful basis for its retention;
• Right to Object: The right to object to the processing of your personal data, including processing for direct marketing purposes;
• Right to Data Portability: The right to obtain your personal data in a structured, commonly used, and machine-readable format;
• Right to Damages: The right to seek compensation for damages sustained as a result of inaccurate, incomplete, or false personal data processed by 1q77.

11 Children's Privacy

The 1q77 platform is strictly intended for individuals who are at least twenty-one (21) years of age. 1q77 does not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from an individual under 21 years of age, that data will be deleted immediately and the associated account will be suspended pending PAGCOR notification.

If you believe that a minor has registered on or accessed the 1q77 platform, please notify us immediately at the contact details in Section 14.

12 International Data Transfers

1q77's primary data processing infrastructure is located in the Philippines or in jurisdictions that provide adequate data protection standards. Where personal data is transferred to service providers located outside the Philippines — for example, cloud infrastructure providers or game software vendors — such transfers are subject to contractual data protection clauses that ensure a level of protection equivalent to that provided under Philippine law.

1q77 will not transfer your personal data to any jurisdiction that does not offer adequate data protection safeguards without your explicit consent or a lawful exception under the DPA.

13 Amendments to This Privacy Policy

1q77 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered users via the email address on file or via a prominent notice on the 1q77 platform prior to the effective date of the change. Continued use of the 1q77 platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

The most current version of this Privacy Policy is always accessible at 1q77.club/privacy-policy. The "Last Updated" date at the top of this page reflects the date of the most recent revision.

14 Contact & Data Protection Officer

For privacy-related inquiries, data access requests, complaints, or any concerns about how 1q77 processes your personal data, please contact our Data Protection Officer:

If you are not satisfied with our response to your data privacy request, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file an NPC complaint is available through PAGCOR-published responsible gaming resources and the NPC's official channels.